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HomeMy WebLinkAboutNCG160117_Regional Office Historical File Pre 2018<� ROY COOPER ° } Governor MICHAEL S. RRGAN Secretary Environmental Quality May 25, 2017 Mr. Steve Nearhood, Vice President Blyth Construction, Inc P.O. Box 31635 Charlotte, NC 28231 Subject: Multimedia Compliance Inspection Blyth Construction, Inc Plant Number 2 Cabarrus County Dear Mr. Nearhood: Ori Tuvia, Donna Cook and Andrew Martin from the Mooresville Regional Office conducted a multimedia compliance inspection of Blyth Construction,'Inc. Plant 2 at Concord on May 9,2017, for permits -and programs administered by the following Divisions: Division of Air Quality NC ID: 1300074 Division of Energy, Mineral and Land Resources Stormwater Permit Number: NCG160117 Division of Waste Management EPA ID: NCD981019003 David Fleming, George Bennett and Your cooperation during the multimedia inspection was much appreciated. Enclosed are the air quality, Stormwater and waste management reports. The inspection resulted in one area of concern for the stormwater permit which the Division of Energy Mineral and Land Resources might address via separate inspection in the future. State of North Carolina I Environmental Quality I Mooresville Regional Office Mooresville Regional Office 1 610 E. Center Ave Suite 301 1 Mooresville, NC 28117- 704-663-1699 T 1 704-663-6040 F If you have any questions regarding this multimedia inspection; please contact Ori Tuvia, Division of Water Resources at (704) 663-1699. Sincerely, Ori Tuvia, Environmental Engineer Mooresville Regional Office Division of Water Resources, DEQ Enclosure: Air Quality Inspection Report Stormwater Inspection Report Waste Management Report c: DAQ MRO Files DEMLR MRO files CD-VR__MRO-Fi1�J DWM MRO Files NORTH CAROLINA DIVISION OF AIR QUALITY Inspection Report Date: 05/16/2017 Facility Data' Blythe Construction, Inc., Plant No. 2 7450 Poplar Tent Road Concord, NC 28027 tat: 35d 24.2320m Long: 80d 42.1000m SIC: 2951 / Paving Mixtures And Blocks NAILS: 324121 / Asphalt Paving Mixture and Block Manufacturing Contact Data Facility Contact Authorized Contact Technical Contact David Fleming Allen Hendricks Steve Nearhood Plant Foreman Vice President/Asphalt Plant Superintendent (704) 788-9733 Division Manager (704) 375-8474 (704) 375-8474 Comments: Partof Multimedia inspection Inspector's Signature: �( ' y Date of Signature: Total Actual emissions in TONS/YEAR: TSP' S02 NOX 2.45 2.39 2014 4.21 2009 2.59 0.0100 4.75 Mooresville Regional Office Blythe Construction, Inc., Plant No. 2 NC Facility ID 1300074 County/FIPS: Cabamis/025 Permit Data Permit 05982 / R16 Issued 3/17/2016 Expires 8/31/2023 Classification Synthetic Minor Permit Status Active Current Permit Application(s) None Program Applicability SIP NSPS: Subpart I Compliance Data Inspection Date 05/16/2017 Inspector's Name Ori Tuvia Operating Status .Operating Compliance Code Compliance - inspection Action Code . FCE On -Site Inspection Result Compliance VOC CO 3.47 9.69 1.95 5.65 - P1VI10 * HAP :2.:41� 461.07 1.53 256.38 * Highest HAP Emitted (i Ive Yeai Violation History:. None Date Letter Type Rule Violated Violation Resolution Date 'erformed Stack Tests since last FCE: None Date Test Results Test Method(s) Source(s) Tested Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 2 Type Action: _X-Full Compliance _ Partial Compliance _ Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Tracking: X Date submitted for initial review 05/18/2017 _ IBEAM WARNING// NOD, NOV, NRE X IBEAM Inspection, list date inspected X IBEAM Document X IBEAM Inspection, list date draft is submitted X IBEAM LAT/LONG, Facility Locked X IBEAM Inspection, pollutants/programs checked X IBEAM LAT/LONG, Coordinates checked IBEAM Complaint X IBEAM Planning, Next Inspection Date 05/01/2018 Directions: Travel from Mooresville to Concord via Highway 3 South; turn right on Odell School Road; turn right at the stop light onto Poplar Tent Road due to the no left turn; make a U turn at the next stop light; 0.7 mile turn left on Goodman Road (road prior to Interstate 85). Blythe Construction, Inc., Plant No. 2 is located on the left on the corner of Poplar Tent Road and Goodman Road. The street address of this company is 7450 Poplar Tent Road. Safety Equipment: This company requires that a hard hat, ear protection, steel toe shoes, and safety glasses be. worn by the inspector at the asphalt plant. Safety Issues: No safety issues were noted by me during the inspection. Lat/Long: A review of the facility's coordinates on "Maps of DAQ Regulated Facilities" indicates the facility latitude and longitude coordinates are accurate. No changes to the latitude and longitude coordinates of this facility in IBEAM are needed. Latitude and longitude coordinates of this facility are locked in IBEAM. Email Contacts: The emails for the facility, authorized, technical, and invoice contacts were verified by Mr. David FleminG,.,plant foreman. No -changes to the email contacts are needed in IBEAM.: The purpose of this site visit was to conduct a multimedia inspection on May 9 and May 16, 2017. This asphalt plant was not in operation on May 9, 2017, but was in operation on May 16, 2017. Blythe Construction, Inc. operates. a drum mix type asphalt plant that produced 207,818 tons of asphalt while burning natural gas during calendar year 2016. The asphalt plant operates on a varied schedule, which is dependent upon weather conditions and road projects. This facility is subject to NSPS Subpart I -"Standards of Performance for Hot Mix Asphalt Facilities". Mr. Steve Nearhood; plant superintendent; Mr. David Fleming, plant foreman; Mr. George Bennett, equipment engineer; accompanied Andrew Martin of DWM; Donna Cook of DAQ and me during this inspection on May 9, 2017. Mr. David Fleming, plant foreman, accompanied Mr. Brad Newton of DWM and me during the inspection on May 16, 2017. Mr. Fleming stated that this plant operates currently 7 a.m. to 7 p.m., 4 to 5 hours per day on average, 5 days per week, 48 weeks per year. 2. Facility Contact Information: During the inspection, I verified the facility contact information in IBEAM with Mr. Fleming. No changes are needed in IBEAM. Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 3 Compliance history file review: No problems have been noted in the last five years by DAQ prior to this inspection: The current compliance status is discussed in the following sections. 4. Observations of permitted air emission sources and control devices: ^� Emission Emission Source . Control Control System Source ID. Description System ID Description I DJHS2 (NSPS) natural gas/No. 2 fuel CD-1, CD-2 inertial separator (ID No. ' oil/recycled No. 2 fuel �CD-I) installed in series oil/No. 4 fuel with a baghouse (13,445 oil/recycled No. 4 fuel square feet of filter area; oil -fired hot mix ID No. CD-2) asphalt/RAP rotary drum ! dryer (350 tons.per hour maximum capacity; 117 E million Btu per hour maximum heat input) Natural gas is the primary fuel source for the rotary drum dryer. No. 2 fuel oil is the backup fuel source the rotary drum dryer. Recycled No. 4. fuel oil was last burned in the rotary drum dryer during February 2009. No. 2 recycled and No. 4 fuel oils are listed in the permit description.as fuel sources for the rotary drum dryer, but have never been burned in this dryer. This" company.reported that 56,826 decatherms of natural gas was combusted by the rotary drum dryer (1D No. DJHS2) and liquid asphalt hot oil heater (ID No. IES-7) during calendar year 2016. This i company did not use any No. 2 fuel oil, recycled No. 2, No. 4 fuel oil, and recycled No. 4 fuel oil in the rotary drum dryer during calendar year 2016. Particulate matter emissions from the mix side of the rotary drum dryer are exhausted into the inertial f separator (ID No. CD-1; referred to by this company as, the. knockout box or KO - box) .and then to the pulse jet type bagfilter (ID No.. CD-2). At the base of the inertial separator (ID No. CD -I), the particulate i matter emissions are fed into, the recycled collar. From the bagfilter (ID: No. CD-2), the particulate matter j emissions are screw conveyed into the top of a box (referred to as LPOD; box with rotary air lock on bottom) and screw conveyed into the recycled collar of the rotary drum dryer. This company has a gauge - measured in inches of water that is used to determine the pressure differential across the bagfilter. The gauge is located on -the control panel inside the plant office. ! Observed:. Rotary drum dryer was firing on natural gas during the inspection. Pulse jet type bagfilter was in operation. I observed no -visible emissions from the: exhaust of the bagfilter stack. SCR-01, SCR-02 two (2): vibrating double I j deck screens (300 tons N/A' ) N/A j per -hour maximum Y process rate, each) Sand and aggregate are placed in the six bins (five active bins and one spare bin) by a front end loader. These materials are conveyed via six virgin. aggregate feeder belts (belt under each of the six feeders in bottom of.each bin; listed as conveying operations IES-18 in the insighificantlexempt activities) to one virgin aggregate collector conveyor belt (listed as conveying operations ]ES-18 in insignificant/exempt Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 4 activities); to one virgin aggregate incline conveyor belt (listed as conveying operations IES-18 in insignificant/exempt activities) and then to a vibrating double deck screen (ID No. SCR-01; 4' x 8'). After the screening process, these materials are conveyed via one virgin aggregate scale conveyor belt (listed as conveying operations IE5-18 in insignificant/exempt activities) to one virgin aggregate slinger conveyor belt (listed as conveying operations IES-18 in insignificant/exempt activities) and then into the inlet of the rotary drum dryer. A front end loader is used to place the reclaimed asphalt pavement (RAP) into three grizzly screens and then dropped into its respective three feeder bins (referred to rap storage bins; IES-20 in insignificant/exempt activities). From the three feeder bins (IES-20), the RAP is conveyed via three feeder belts (belt under the feeder in bottom of bin; listed as conveying operations IES-18 in insignificant/exempt activities) then into another collector conveyor belt (listed as conveying operations IES-18 in insignificant/exempt activities), and then into the vibrating double deck screen (5' x 10 ; ID No. SCR-02). After the screening process, the RAP is conveyed via one scale conveyor belt (referred to also as the weigh bridge conveyor; listed as conveying operations IES-18 in insignificant/exempt activities) into the recycled collar of the rotary drum dryer. Mr. Fleming stated that 30% RAP was being used in hot mix asphalt product. This company hired an outside contractor, Black Rock Crushing, to crush RAP at this asphalt plant. Mr. Fleming stated that the crushing of RAP was not been conducted during the inspection. I observed no portable RAP crushing plant at this facility. An. email dated May 9, 2017 from Steve Nearhood, plant superintendent, stated that 63,297.74 tons of RAP was crushed by Black Rock Crushing during calendar year 2016. Observed: Two vibrating double deck screens (one for sand and aggregate, and one for RAP) were in operation. I observed no visible emissions from the two vibrating double deck screens. ES_ 1, ES-13, ES-14 three (3) 200 tons _ electrically heated hot N/A N/A mix asphalt silos . ,.:.:. . Hot mix asphalt product from the rotary drum dryer is conveyed via the drag slat to the two hot mix asphalt (lima) conveyors (referred to as traverse conveyors by this company; listed as conveying operations IES-18 in insignificant/exempt activities). Two hma conveyors are located above the three hot mix storage silos (ID Nos. ES-1, ES-13, and ES-14 or company ID Nos. 1, 2, and 3). Hot mix asphalt product is transported by the two hma conveyors into a designated hot mix storage silo by the plant operator. Hot mix asphalt is stored in the three electrically heated silos. Only the cone portion of the three silos are heated. Hot mix asphalt is gravity dropped from the three storage silos into the beds of dump trucks. Observed: Hot mix asphalt was being stored in the three storage silos (Nos. ES-1 or 1, ES-13 or 2, and ES-14 or 3) during the inspection. Hot mix asphalt was being gravity dropped from one storage silo (ID No. ES-14 or #3) into the beds of dump trucks during the inspection. The other two storage silos (ID Nos. ES-1 or #1; and ES-13 or #2) were not in use during the inspection. I observed 10% visible emissions from the top of the three storage silos. TL truck loadout r� N/A N/A Hot mix asphalt is gravity dropped from the three storage silos (ID Nos. ES=1, ES-13, and ES-14 or company ID Nos. 1, 2, and 3) into the beds of the dump trucks. Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 5 Observed: Hot mix asphalt was being gravity dropped from one storage silo (ID No. ES-14 or #3) into the beds of dump trucks during the inspection. I observed no visible emissions from gravity dropping of asphalt from the one storage silo (ID No. ES-14 or #3) into the beds of dump trucks during the inspection. Observations of insignificant air emission sources and control devices listed on the current permit: Insignificant/Exempt Activities Source ` Exeffi tion Regulation Source of TAPS? Source of Title V (. p Pollutants? a 000 gallon recycled fuel IES-1 - 15, Q .0102 (c)(1)(D)(' Yes Yes I oil above -ground storage tank 2 1 No. 4 recycled fuel oil is used as a fuel source for the rotary drum dryer. A heat exchanger (pre -heater) is used to heat the No. 4 recycled fuel oil prior to the rotary drum dryer. Observed: No. 4 recycled fuel oil has not been used since February 2009. Mr. Fleming stated that the vertical No.. 4 recycled fuel oil tank was empty during the inspection. . IES-3a - 20,000 gallon liquid asphalt aboveground storage tank 2Q .0102 (c)(1)(L)(xii) Yes Yes Liquid asphalt is stored in a vertical tank.. Liquid asphalt is mixed with sand and aggregate in the rotary drum and then heated by the dryer to produce the hot mix asphalt product. Observed: Liquid asphalt was being mixed in the rotary drum with sand and aggregate and then heated by the dryer to produce the hot mix, asphalt product. I observed no visible emissions from the vertical liquid asphalt storage tank. IES-4a - 20,000 gallon liquid asphalt Yes Yes aboveground storage tank `� 12Q.01102(c)(1)(L)(xii). _ .. ( " • _ , Liquid asphalt is stored in a vertical tank. 'Liquid asphalt is mixed with `sand and aggregate in the rotary drum and then heated by the dryer to produce the hot mix asphalt product. Observed: Liquid asphalt was being mixed in the rotary drum with sand and aggregate and then heated by the dryer to produce the hot mix asphalt product. I observed no visible emissions from the vertical liquid asphalt storage tank. IES-7 - natural gas / No. 2 fuel oil- fired storage tank heater (2.058 2Q .0102 (c)(2)(B)(i)(II) Yes Yes million,Biu per hour, maximum heat input) Heatec model hot oil heater (manufactured date of January 2003) is used to heat the hot oil in three liquid asphalt tanks, one recycled No. 4 fuel oil pre -heater (heat exchanger), drag slat and asphalt lines.. Natural gas is the primary fuel source -for the hot oil heater. No. 2 fuel oil is listed as the backup fuel source for the hot oil heater. Observed: Hot oil heater was operating on natural gas during the inspection. j IES-8 - 20,000 gallon liquid asphalt (� i aboveground storage tank F2.0102 (c)(1)(L)(xii) t Yes Yes I Liquid asphalt is stored in a vertical tank Liquid asphalt is mixed with sand and aggregate in the rotary Blythe Construction, Inc., Plant No..2 May 16, 2017 Page 6 drum and then heated by the dryer to produce the hot mix asphalt product. Observed: Liquid asphalt was being mixed in the rotary drum with sand and aggregate and then heated 1. by the dryer to produce the hot mix asphalt product. I observed no visible emissions from the vertical liquid asphalt storage tank. _ . ............. _ _ IES-9 - five (5) pound propane bottle 29 .0102 (c)(1)(D)(i) No---�- No Propane is used to heat the asphalt unloading lines. No heating of the asphalt unloading lines by propane was being conducted during this inspection. ! IES-10 - 100 gallon propane bottle 2Q .0102 (c)(1)(D)(i) No No Propane is used to heat the liquid asphalt lines. Bottle of propane was in storage IES-11 - 100 gallon propane bottle 2Q .0102 (c)(1)(D)(i) ^-� No No Propane is used to heat the liquid asphalt lines. Bottle of propane was in storage. IES-17 — 20,000 gallon fuel oil "2Q .0102 I(1)(D)(i) Yes Yes storage tank No. 2 fuel oil is stored in a horizontal tank. No. 2 fuel oil is used as the backup fuel source for the rotary drum dryer (ID No. DJHS2) and hot oil heater (ID No. IES-7). . Observed: No. 2 fuel oil tank was not in use during this inspection. IES-18 -conveying operations 2Q .0102 (c)(2)(E)(i) No F Yes Observed: Ten aggregate conveyors, six RAP conveyors and two hma (traverse) conveyors were in, operation during the inspection. IES-19 - truck bed lubrication and 'F2Q0102 2 _-_ c ()( )(E )()i No Yes release agent application Observed: Release agent (manufacturer, ChemStation of NC; product #81941; and ingredient, urea from 10 to 25% by weight) is sprayed ih the beds of trucks prior to the asphalt loadout process. Release agent stops the bonding of the -asphalt to the beds of the dump trucks. I observed that the release.agent was being sprayed in the beds of the dump trucks with no visible emissions observed. - g... p _ .. _ .. __ ... IES-20 —three (3) RAP storage bins 2Q 0102 (c)(2)(E)(i) No Yes j Observed: Reclaimed asphalt pavement (RAP) is placed byfront end loader into three grizzly screens and then dropped below into its respective three feeder bins (storage bins). The three feeder bins (storage. bins) were in use during the inspection. I observedno visible emissions from,the three feeder bins (storage bins). Observations of air emission sources and control devices not listed Ion the current permit: a. This company has a heat exchanger (referred by this company as a pre -heater) that is used to heat the No. 4 recycled fuel oil from the 15,000 gallon No. 4 recycled fuel oil vertical aboveground storage tank (ID No. IES-1) prior to the rotary drum dryer. This tank was empty during the inspection. b. This company uses a product #7339 containing d-limonene (10% to 25% by weight) from ChemStation of NC to clean the drag slat. . C. This company has the following sources at this facility: one portable cement silo with associated bagfilter powered by a portable diesel -fired engine (manufacturer: ISUZU Motors Limited; model. Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 7 year: 2015; 65.7 bhp and specification in file of facility); two bins containing 50% ABC stone; 50% crushed RAP; and 1 % RAP; one pugmill; and truck tanker containing an asphalt emulsion. The final product produced by the pugmill;is used on paving Interstate 85. This engine is not subject to NESIF11AP 4Z or NSPS 4I since it is portable. Since the emissions from process could not be determined during this inspection; this company should submit a permit determination for these sources. The compliance status of this facility may change if these sources are required to be permitted. 7. Compliance with pecific permit conditions and limitations: a. Condition A. 2. "Permit Renewal and Emission Inventory Requirement" states that at least 90 days prior to the expiration date of this permit, the permittee shall request permit renewal by letter with AA application form and submit the air pollution emission inventory report with certification sheet for 2022 calendar year to MRO DAQ. Observed. I informed Mr. Fleming that the current air permit will expire on August 31, 2023: Compliance with this stipulation is indicated. b. - Condition A. 3. "Particulate. Control Requirement" as required by 15A NCAC 2D .0506 "Particulates from Hot Mix Asphalt Plants" states: a.. Particulate matter emissions resulting from.the operation. of a hot mix asphalt plant shall not exceed allowable emission rates. b. Visible emissions from stacks or vents at a hot mix asphalt plant shall be less than 20 percent opacity when averaged over a six_minute period. C. Fugitive, dust emissions shall be controlled as required by 15A NCAC 2D .0540 y _ "Particulates From Fugitive. Dust Emission Sources." d. Fugitive emissions for sources at a hot mix asplialt plant not covered elsewhere under this Rule shall not exceed 20 percent opacity averaged over six minutes. Observed. During the inspection, I- observed no visible or fugitive emissions from this facility. Compliance with this stipulation is indicated. c. Condition A. 4. "Sulfur Dioxide Control Requirement" as required by- 15A NCAC 2D .0516 "Sulfur Dioxide,Emissions from Combustion Sources" states that the sulfur dioxide emissions from drum mix asphalt plant (ID No. ES 1-1) shall not exceed 2.3 pounds per million Btu heat input. Observed. Per MRO memo, 2D .0516 analysis dated 04/10/97, compliance is indicated for No. 1 fuel oil, No. 2. fuel oil, natural gas, butane, propane, and wood fuel. This asphalt plant is not exceeding this limitation for sulfur dioxide emissions. Compliance with�this stipulation was indicated during the permit application process. d. Condition A. 5. "Visible Emissions Control Requirement" as required by 15A NCAC 2D .0521 "Control of Visible Emissions" states that the visible emissions from the emission sources, manufactured after July 1, 1971, are limited to 20 percent opacity when averaged over a six -minute period. Blythe Construction, Inc., Plant No. 2 May 16, 2017. Page, 8 Observed. During the inspection, I observed 10% visible emissions from the top of the three storage silos. This facility is not -exceeding the 20% opacity limit.. Compliance with this stipulation is indicated. e. Condition A. 6. 15A NCAC 2D .0524 "New Source Performance Standards" states that for drum dryer (ID No. DJHS2), the permittee must comply with all applicable provisions including notification, testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards" (NSPS) as promulgated in 40 CFR Part60, Subpart I, including Subpart A, "General Provisions". a. NSPS Emissions Limitations -As required by 15A NCAC 2D .0524 states that the permittee shall not discharge or cause the discharge into the atmosphere from any affected source any gases which: i. Contain particulate matter in excess of 90 mg/dscm (0.04 gr/dscf); or ii. ' Exhibit 20 percent opacity or greater. Observed. During the inspection, I observed.10% visible emissions from the top of the three storage silos. This facility is not exceeding the 20% opacity limit. Compliance with this stipulation is indicated. f. Condition A. 7. "Notification Requirement" as required by 15A NCAC 2D .0535, the permittee of a source of excess emissions that last formore than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall notify the Director or his designee of any.such occurrence by s 9:00 a.m. Eastern time of the Division's next business day of bocoming aware of the occurrence. Observed. Based on records review and the conversation with Mr. Fleming, no excess emissions have occurred at the facility. Compliance with this stipulation is indicated. g. Condition A. 8. "Fugitive Dust Control Requirement as required by 15A NCAC 2D .0540 "Particulates From Fugitive Dust Emissions Sources" states that the permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive . complaints or excess visible emissions beyond the property boundary. If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 2D-.0540(f). Observed. MRO DAQ has not received any fugitive dust emissions complaints regarding this facility: Mr. Fleming stated that Vulcan Construction Materials, LLC, Cabarrus Quarry has a water truck that wets the unpaved areas at this asphalt. plant for this company. I observed that no fugitive emissions from the unpaved areas at this facility. Compliance with this stipulation is indicated. Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 9 h. Condition A. 9. "Testing Requirement" states that under the provisions of North Carolina General Statute 143-215.108 and in accordance with 15A NCAC 2D .0605, the permittee shall demonstrate compliance with the emission limits) by testing the emission source(s) for the specified pollutant(s) as follows: Affected'Source(s) Pollutant Target. Parameter Test Method natural gas / No..2 fuel oil/ recycled No. 2 fuel oil / No. 4 fuel oil / recycled No. 4 fuel oil- fired hot mix asphalt / RAP rotary drum dryer PM(TSP) 60 lb/hr Method 5 (350 tons per hour maximum capacity; 117 million Btu per hour maximum heat input) (DJHS2) natural gas J No. 2 fuel oil/ recycled No. 2 fuel oil / No. 4 fuel oil / recycled No. 4 fuel oil- fired hot mix asphalt / RAP rotary drum dryer PM(TSP) 601b/hr Method (350 tons per hour maximum capacity;.117 202 million Btu per hour maximum heat input) (DJHS2) natural gas / No. 2 fuel oil/ recycled.No. 2 fuel oil / No. 4 fuel oil / recycled No. 4 fuel oil- fired hot mix asphalt / RAP. rotary drum dryer Visible 20%opacity Method (350 tons per hour maximum capacity; 117 Emissions .9 million Btu per hour maximum heat input) (DJHS2) a. The Permittee shall arrange for air emission testing protocols to be provided to µ - the DAQ prior to testing. Testing protocols are not required to be pre -approved by the DAQ prior to testing. The DAQ shall review testing protocols.for pre-. approval prior to testing if requested by the Pemuttee at least 45 days before conducting the test. b. To afford the regional supervisor, DAQ, the opportunity to have an observer present, the permittee shall PROVIDE the regional office, in WRITING, at least. 15 days notice of any required performance test(s). C. Two copies of the test results must be submitted. to the regional supervisor, DAQ, in accordance with the approved procedures of the Environmental Management Commission by November 11, 2021. d. This permit may be revoked, with proper notice to the permittee, or enforcement procedures initiated, `if. the results of the test(s) indicate that the facility does not meet applicable limitations. e. The source shall be responsible for ensuring, within the limits of practicality, that the equipment or process being tested is operated at or near its, maximum normal production rate, or at a lesser rate if specified by the director or his delegate. f. All associated testing costs are the responsibility of the permittee. Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 10 Observed. This facility is required per DAQ memo to perform the particulate matter (methods 5 and 202) and visible emissions (method 9) testing on the rotary drum mix asphalt dyer once every ten years. This office sent a letter dated September 13, 2013 advising this facility of emission testing procedures. This testing and its results will have to be submitted to MR0 DAQ by November 11, 2021. The last stack testing for visible (EPA reference method 9) and particulate (EPA reference method 1-5-filterable PM & 202-condensible PM)_ emissions testing of the hot mix asphalt" rotary drum dryer (ID No. DJHS2) was performed by Kleinfelder Southeast, Inc. on November 11, 201.1. This plant was burning natural gas and actual production rate of asphalt was 298.3 tons per hour during this testing. The results of this testing indicated that this asphalt plant had a filterable particulate matter (PM) emission rate of 7.7 mg/dscm; total particulate matter (PM ) emission rate of 1.08 lb/hr; condensable particulate matter (PM) emission rate of 0.21 lb/hr; and Method 9 visible emissions evaluation for the highest six -minute average was 11.3% opacity. These tests . demonstrated compliance with the NSP5 filterable particulate matter (PM) emission limit of 90 mg/dscm; total particulate matter (PM) emission limit of 59.81b/hr in accordance with 15A NCAC 2D .0506 "Particulates From Hot Mix Asphalt Plants"; and visible emissions limitation of 20% opacity in accordance with j5A NCAC 2D .0521 "Control of Visible Emissions" and 40 CFR Part 60 NSPS Subpart I "Standards of Performance For Hot Mix Asphalt Facilities". Compliance with this stipulation is indicated. Condition A. 10. "Fabric Filter Requirements including cartridge filters, baghouses, and other dry filter particulate collection devices as required by 15A NCAC 2D .0611 states that particulate matter emissions. shall be controlled as described in the permitted equipment list. a. Inspection and Maintenance Requirements -To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the permittee shall perform,, at a minimum, .an. annual (for each 12 month period following the initial inspection) intemal inspection of each bagfilter system. In addition, the permittee shall perform periodic inspections and maintenance as recommended by the equipment manufacturer. b. Recordkepping Requirements -The results of all inspections and any variance from manufacturer's recommendations or from those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a logbook. _ Records of all maintenance activities shall be recorded in the logbook. The logbook (in written or electronic format) shall be kept on -site and made available to DAQ personnel upon request. Observed.. Mr. Fleming showed me the logbook indicating that inspection and maintenance activities are being performed on the bagfilter by this company. Internal inspections of this bagfilter was conducted by this company on 2/9/17; 4/1116; 11/19/15; 8/8/15; and 5111115. Compliance with this stipulation is indicated. Condition A. 11. "Inertial Separator Requirements" as required by 15A NCAC 2D .0611 states that particulate matter emissions shall be controlled as described in the permitted equipment list. Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 11 a. Inspection and Maintenance Requirements -To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory. limits,* the permittee shall perform, at a minimum, an annual (for each 12 month period following the initial inspection) inspection of the inertial separator system. In addition, the permittee shall perform periodic inspections .and maintenance as recommended by the equipment manufacturer. b. ,Recordkeeping Requirements -The results of all inspections and any variance from. -the manufacturer's recommendations or from those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a logbook. Records of all maintenance activities shall be recorded in the logbook. The logbook (in written or electronic format) shall be kept on -site and made available to DAQ personnel upon request. Observed. Mr. Fleming showed me the'logbook indicating that inspection and maintenance activities are being performed on the inertial separator (referred to as the knockout box or KO box) by this company: Inspections of the inertial separator were conducted by this company on 1/26/17; 1/29/16; and 5/13/15. Compliance with this stipulation is indicated: k. Condition A. 12. "Toxic Air Pollutant Emissions Limitation and Reporting Requirements" states that pursuant to 15A NCAC 2D .l 100 "Control of Toxic Air Pollutants" and in accordance with the approved application for an air toxic compliance demonstration, the following permit limits. shall not be,exceeded: Emission Affected Source(s) Toxic Air Pollutant Limit natural gas / recycled No: 2 / recycled No. 4 / Arsen'ic-& Compounds - No. 2 / No. 4 fuel oil -fined hot mix asphalt /RAP (total mass of elemental rotary drum dryer (350 tons per hour. -maximum- AS, arsine and all 1.71 lb/yr capacity; 117 million Btu per hour maximum inorganic compounds) heat input)(DJHS2) (ASC) natural gas / recycled No. 2 / recycled No. 4 / -No. 2 / No. 4 fuel oil -fired hot mix asphalt /RAP rotary drum dryer (350 tons per hour maximum : capacity; 117 million Btu per hour maximum Benzene (71-43-2) 1200.12 l 20 heat input)(DJHS2) natural gas / recycled No.. 2. /. recycled No. 4 No..2 / No. 4. fuel oil -fired hot mix asphalt /RAP_ rotary drum dryer (350 tons per hour maximum Formaldehyde (50-00-0) 1.09 lb/hr capacity; 117 million Btu. per.hour maximum heat mput)(DJHS2) natural gas / recycled No. 2 / recycled No. 4 / No. 2 / No. 4 fuel oil -fired hot mix asphalt /RAP ' Mercury, vapor rotary drum dryer (350 tons per hour maximum (Component of HGC) 0.0. 021 capacity; 117 million Btu per hour maximum (7439-97-6) . . lb/24-hrs heat input)(DJHS2) i Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 12 three (3) 200 tons electrically heated hot mix asphalt silos(ES-1,ES-13,ES-14) Benzene (71-43-2) 11.91 lb/yr' three- (3) 200 tons electrically heated hot mix Formaldehyde (50-00-0) 0.029 lb/hr asphalt silos(ES-1,ES-13,ES-14) - truck loadout (TL) ; Benzene (71-43-2) _`0.831b/yr truck loadout (TL) F128 ormaldehyde (50-00-0) Fio�(,0 natural gas / recycled No. 2 / recycled No. 4 / No. 2 / No. 4 fuel oil -fired hot mix asphalt /RAP ' Nickel metal (Component 0.53 rotary drum dryer (350 tons per hour maximum . of 373024/NIC) (7440-02- lb/day capacity; 117 million Btu per hour maximum 0) .heat input)(DJHS2) Observed. This facility has shown compliance with 2D .1100 by modeling emissions of arsenic, benzene, formaldehyde, nickel, and mercury. The modeled limits and the actual emission rates taken from calendar year 2014. -did not exceed the above referenced TPERs. This company also has production records to verify that the TPERs are not being exceeded. Compliance with this stipulation is indicated. 1. Condition A. 13. "Control and Prohibition of Odorous Emissions" as required by 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" states that the . permittee shall not operate the facility without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. Observed. MRGDAQ,has riot received -any odor complaints concerning this facility. , During the inspection,,the asphalt plant was in operation. I detected a noticeable asphalt odor at this facility which is consistent with normal operations. No violation of the odorous emissions regulation (.1806) was. documented. Compliance with this stipulation is indicated. In. Condition A. 14. "Limitation to Avoid 15A NCAC 2Q .0501 "-Pursuant to 15A NCAC � 2Q .0315 Synthetic Minor Facilities,". to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement fora Permit", as requested by the permittee, facility -wide emissions shall be less than the following: Pollutant Emission Limit. Tons per consecutive_ 12-monthperiod) SOz :100 CO 100 a. operations Kesmcuons-1 U the following restrictions shall apply: i. the production of asphalt shall be less than 1,489,152 tons per consecutive 12-month period when exclusively combusting natural gas; ii. the asphalt produced shall be less than 1,489,152 tons per consecutive 12-month period when exclusively combusting No. 2 or recycled No. 2 fuel oil that is 0.5 percent by weight sulfur; Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 13 iii. ' the asphalt production of asphalt shall be less than 755,774 tons per consecutive 12-month period when exclusively combusting No. 4 or recycled No. 4 fuel oil that is 1 per by weight sulfiar, iv. If multiple fuels are used, emissions should be determined using the sum of the individual emissions rates. b. Recordkeging Requirements i. The permittee shall record monthly and total annually the following: A. amount of asphalt produced and the associated fuel combusted to produce the asphalt. B. the.facility-wide S02 and CO emissions. ii. Fuel supplier certification shall be kept on-site,and made available to DAQ personnel upon request. Observed. The monthly and annual asphalt production records and calculated emissions data of SOz and CO are compiled by Mr. SteveNearhood, plant superintendent.. Recycled No. 4 fuel oil was not combusted by the rotary drum dryer during calendar year 2016. Recycled No. 4 fuel oil was last combusted in the rotary drum dryer during February 2009. This company has fuel oil. certification records on site indicating that the sulfur content of the No. 4 recycled fuel oil is below the allowable. limit. Compliance with'this stipulation is indicated. C. Reporting Requirements Within 30 days after each calendar year, regardless of the actual emissions, the permittee shall submit the following to the Regional Supervisor, DAQ, in writing: i. emissions and/or.operational data listed below. The data should include monthly and .12 month totals for the previous 12 month period. A. the total facility -wide SO2 and CO emissions for the previous 12 months; B. monthly and total asphalt produced and the associated fuel combusted to produce the asphalt for the previous 12 months. Observed. -The annual report for calendar year 2016 was received by this office on January 17, 2017. This company reported the following information: 0.040 tons of sulfur dioxide (S02) emissions; 14.182 tons of carbon dioxide (CO) emissions; 207,818 tons of asphalt when combusting 56,826 decatherms of natural gas for rotary drum dryer (ID No. DJHS2) and hot oil heater (ID No. IES- 7); and no fuel oils were combusted in the rotary drum dryer during calendar year Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 14 2016. Compliance with this stipulation is indicated. n. Condition A. 15. "Vendor Supplied Recycled N6(s). 2 and 4 Fuel Oil Requirements" states,in accordance with Rule 2Q .0317, the permittee is avoiding the applicability of Rule 2Q .0700 by using recycled fuels which are equivalent to their virgin counterparts. The permittee is allowed to use the. recycled fuel oil(s). supplied by a DAQ-approved vendor as follows: a. Specifications -The recycled fuel oils have to be equivalent to unadulterated fossil fuel by meeting the following criteria: Constituent/Pro ert Allowable ]Level Arsenic 1.0 ppm maximum Cadmium 2-.0 ppm maximum Chromium 5.0 ppm maximum Lead 100 ppm maximum Total Halogens 1000 m maximum Flash Point No. 4 130°F minimum Sulfur . No.'4 2.0% maximum (by weight) Ash l A0 o. maximum b. The permittee is responsible for ensuring that the recycled fuel oil(s),-as received at the site, meet(s) the approved criteria for unadulterated fuel. The permittee is held responsible for any discrepancies discovered by DAQ as a result -of -any sampling and analysis of the fuel oil(s)., C. Recordkeeping Requirements -The permittee shall maintain at the facility for a minimum of three years, and shall make available to representatives of the DAQ upon request, accurate records of the following: i. The actual amount of recycled fuel oil(s) delivered to, and combusted at the facility on an annual basis. ii. Each load of recycled fuel oil received.shall include the following: A. A delivery manifest document clearly showing the shipment content and amount, its place and date of loading, and place and date of destination. B. A batch specific analytical report that contains an analysis for all constituents/properties listed above. Analytical results of the samples representative of: the recycled oil shipment from the vendor shall be no more than one year old when received. C. Batch signature information consisting of the following: a batch number, tank identification with batch volume of recycled oil, date and time the batch completed treatment, and volume(s) delivered. Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 15 D. A certification indicating that the recycled fuel oil does not contain detectable PCBs (<2ppm). d. Reporting Requirements -Within 30 days after each calendar year, .regardless of the amount received or combusted, the permittee shall submit in writing to the Regional Supervisor, DAQ, the following: i. A summary • of the results of the analytical testing for the previous 12 . months. ii. The total gallons of recycled fuel oil(s) from each approved vendor combusted at the facility for the previous 12 months: e. The DAQ reserves the right to require additional testing and/or monitoring of the recycled fuel oil(s) on an annual basis or without notice. Observed. This company is keeping records of the recycled No. 4 fuel oil delivered and combusted by the rotary drum dryer at this facility. The annual report for calendar year 2016 was received by this office on January 17, 2017, Recycled No. 4 fuel oil was not combusted by the rotary drum dryer during calendar year 2016..Compliance with this stipulation is indicated. o. Condition A. 16. "Toxic Air Pollutant Emissions Limitation Requirement" states that pursuant to 15A NCAC 2Q .0711 'Emission Rates Requiring a Permit" for each of the below listed toxic air pollutants (TAP§), the permitted has made a demonstration that facility -wide actual emissions, where all emission release points re unobstructed and vertically oriented,. do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 29.'0711(b). The. facility shall be operated and maintained in such a manner that emissions of any listed TAPs from the facility, including fugitive emissions, will not exceed TPERs listed in 15A NCAC 2Q .0711(b). a. A permit to emit any of the below listed TAPs shall be required for this facility if actual -emissions -from all sources will become greater than the corresponding TPERs. b. PRIOR to exceeding any of these listed TPERs, the permittee shall be, responsible for obtaining a permit to emit TAPs and for demonstrating compliance with the requirements of 15A NCAC 2D :1100 "Control 'of Toxic Air Pollutants'.'. C. In accordance with the approved application, the permittee. shall maintain records of operational information demonstrating that the TAP emissions do not exceed the TPERs as listed below: Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 16 Pollutant Carcinogens Chronic _ Acute �1 .Systemic , Toxicants ; Acute Irritants (lb/yr) lb/day) I Toxicants (lb/hr) ~ (lb/hr) Acetaldehyde (75-07-0) _ :f ` �. j 28.43 Acrolein (107-02-8) 1 1 �0.08 Benzo(a)pyrene.(Component of . 83329/POMTV & 56553/7PAH) 3.044 (50-32-8) j .CFC-11 ) (Trichlorofluoromethane) (75- 589.66 69-4). Carbon disulfide (75-15-0) 7.8 Chromium (VD Soluble — Chromate Compounds 0.026 (Component of CRC) (S-o1CR6) H.exachlorodibenzo- -dioxin 0.007 1 1,2;3,6,7,8 (57653-85-7) i Hexane, n- (110-54-3)-� 46.3 MEK (methyl ethyl ketone, 2- F155.8 93.19 butanone) (78-93-3)i !� Manganese & compounds r -- 1.3 Methyl chloroform (71-55-6) �i 505.4 ; 257.98 Methyiehe chloride (75-09-2) ( 2213.752 — --_ _-- 1.79 Perchloroethylene � 17525.534 (tetrachloroethylene) (127-18-4) Phenol 108-95-2 i. 1.00 Styrene (100-42-5)-j 11.16. Tetrachlorodibenzo-p-dioxin, �— 2,3,7,8- (Component of CLDC 0.0002767 & 83329/POMTV) (1746-01-6) . Toluene (108-88-3) 197.96 j ,� 58.97� Xylene (mixed isomers) (1330- �. 113.7 i F 68.44 20-7) .. i I Observed. This facility has shown compliance with 2D .1100 by modeling emissions of arsenic, benzene, formaldehyde, nickel, and mercury. The modeled limits and the actual emission rates were taken from the emission inventory for calendar year 2014. The above referenced TPERs will not be exceeded from the facility. This company has asphalt production records to verify that the TPERs are not being exceeded. Based on the asphalt production of 207,818 tons while burning natural gas during calendar year 2016, this facility will not exceed the TPERs. The exhaust of the bagfilter stack is vertical and Blythe Construction, Inc., Plant No. 2 May 16, 2017 Page 17 unobstructed. This facility is subject to 2Q .0711(b). Compliance with this stipulation is indicated: . p. Condition A. 17. "Limitation to Avoid 15A NCAC 2D .11_00 "Control of Toxic Air Pollutants" states that to comply with this permit and avoid the applicability of 15A NCAC 2D .1100 "Control of Toxic Air. Pollutants" as requested by the Permittee, the following restrictions shall apply. a. Operations Restrictions -To ensure that the modification of the plant does not require modeling for cadmium, the following restrictions shall apply: 1. the maximum annual asphalt production rate shall be limited to 902,439 tons per consecutive 12 months. 2. Recordkeeping and reporting requirements in the 2Q .0315_ permit stipulation will be used to ensure compliance. Observed:_ This company is keeping the asphalt production and fuel usage records on a daily basis at this plant. This plant produced 207,818 tons .of asphalt during calendar. year 2016. The maximum asphalt production rate is limited to 902,439 tons per consecutive 12 months. Compliance with this stipulation is indicated. 8. GACT/MACT Review: This company does have a portable engine on site that is providing electrical power to a cement silo. Since this engine is classified as "nonroad engines" according to 40 CFR 1068,30, and therefore not subject to 40 CFR, Part 63 NESHAP Subpart 4Z,or 40 CFR, Part 60 NSPS Subpart 4I. 9. Summary of changes needed to the' current permit: No changes are needed to the current permit. 10. Compliance assistance offered.durin the he inspection: No compliance assistance was offered by me during the inspection. I L - Section 112(r) applicability: This facility does not appear to be subject to the requirements of the Chemical Accident Release Prevention Program, Section 112(r) of the Clean Air Act. 12. Compliance determination: Based on my observations, this facility appeared to be in compliance with the applicable air quality regulations at the time of the inspection. OT:lhe c: MRO File G-.\AQ\Shared\WPDATA\COUNTIES\CABARRUS\00074\INSPECT 20170516 Multimedia.doex Compliance Insaection Report Permit: NCG160117 Effective: 10/02/14 Expiration: 09/30/19 Owner: Blythe Construction Inc SOC: Effective: Expiration: Facility: Blythe Construction Inc -Concord County: Cabarrus 7450 Poplar Tent Rd Region: Mooresville Charlotte NC 28207 Contact Person: Steve Nearhood Title:, Phone: 704-375-8474 'Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): On -site representative Daivd Fleming 704-788-9733 Related Permits: Inspection Date: 05/09/2017 Entry Time: 09:30AM Exit Time: 12:45PM Primary Inspector:. OriA Tuvia Phone: 704-663-1699 Secondary Inspector(s): Donna Cook Phone :704-663-1669 Ext.2213 J Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Asphalt Paving Mixture Stormwater Discharge COC Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page: 1 Permit: NCG160117 Owner - Facility: Blythe Construction Inc. Inspection Date: 05/09/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: I Page: 2 Permit: NCG160117 Owner - Facility: Blythe Construction Inc Inspection Date: 05/09/2017 Inspection Type: Compliance Evaluation Reason for visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? 0 ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? E ❑ ❑ ❑ # Does the facility provide .all necessary secondary containment?0 ❑ ❑ ❑ # Does the Plan include a BMP summary? ❑ 0 ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑ # Does the facility provide and document Employee Training? N ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? 0 ❑ T ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? E ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented?0 ❑ ❑ ❑ Comment: Site map should be updated to include the addition of an additional retantion Pond. Qulatative data should be kept on site so it could be exaimned durinq site inspection. Qualitative Monitoring - Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑ Comment: Qulatative data should be kept on site so it could be exaimned during site inspection. Analytical Monitoring Yes No NA NE Has the facility conducted its -Analytical monitoring? ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 1111 ❑ Comment: Analytical analysis is done WAILS Environmental based out of Jacksonville Florida (approved NC lam Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # If the facility has representative outfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment: Yes. No NA NE ❑ ❑ ❑ ❑ ❑ ❑ Page: 3 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WASTE MANAGEMENT HAZARDOUS WASTE SECTION COMPLAINT INVESTIGATION REPORT L FACILITY INFORMATION: Name: Blythe Construction Inc. Plant No. 2 EPA ID Number: NCD981019003 Type of Facility: CESQG Facility Location: 7450 Poplar Tent Rd., Concord, NC 28027 Facility Address: Same Telephone Number: (704) 788-9733 County: Cabarrus 2. AUTHOR OF REPORT: Andrew Martin, Environmental Senior Specialist,. NCDEQ 919-270-3507 andrew.martin@ncdenr.gov Date of Report: May 8, 2017 3. FACILITY CONTACT: David Fleming — Plant Operator Office: (704) 788-9733 4. INSPECTORS: Andrew Martin-NCDEQ Hazardous Waste Section; Ms. Donna Cook of MRO DAQ, Ori Tuvia of MRO DWR 5.. DATE OF INSPECTIONS: May 9, 2017, 9:30a.m. —12:30 p.m. 6. PURPOSE OF. EVALUATION: To determine.compliance with hazardous waste management regulations 7. REPORT: On May 9, 2017, a multimedia inspection at the subject facility was conducted. The facility is currently operating as a Conditionally Exempt Small Quantity Generator (CESQG). Blythe Construction, Inc. operates a drum mix type asphalt plant. The asphalt plant operates on a varied schedule, which is dependent uponweather conditions and road projects. The facility generates used oil and aerosol containers. A 15,000- gallon above ground tank labeled as "Waste Oil" is located onsite. The facility indicates that the tank is not currently in use and empty (See Comments). The tank was historically used as a fuel source for the asphalt plant. The waste oil was recycled oil provided by HazMat Transportation and Disposal. Used oil is collected in 55-gallon containers. 8. COMMENTS AND RECOMMENDATIONS • It is a reminder that per 40 CFR 279.22 (c)(1), containers and aboveground tariks used to store used oil at generator facilities must be labeled or marked clearly with the words "Used Oil." • It is recommended that the facility relabel the waste oil tank to better reflect its contents. • Aerosol cans could be listed as a hazardous waste. It is a reminder that the facility ensure that used, spent, or waste aerosol containers are properly managed by conducting a waste determination per 40 CFR 262.11. B Mail INSPECTOR (DATE) cc: Sean Morris, Western Area Compliance Supervisor Central Office Files - - y FACILITY CONTACT